What Happened
The European Union enacted a comprehensive ban on intentionally added PFAS (per- and polyfluoroalkyl substances) in all food-contact packaging, coatings, and additives. The regulation imposes strict concentration limits: 25 ppb for any single PFAS compound, 250 ppb for the sum of targeted PFAS, and 50 ppm for all PFAS including polymeric variants. The August 12, 2026 compliance date applies to all food-contact packaging placed on the EU market on or after that date, regardless of manufacturing date. This means warehoused stock manufactured before August cannot be sold or used after the deadline.
PFAS compounds have been prized in packaging for decades because of their water and grease resistance, thermal stability, and non-stick properties. They appear in pizza box liners, fast-food wrappers, microwave popcorn bags, takeaway containers, and the grease-resistant coatings on paper and paperboard used across the food industry. Many manufacturers did not know their packaging contained PFAS until recently.
Why This Matters for UK Manufacturers
While the UK left the EU, UK food businesses that source packaging from European suppliers or export food to the EU must comply. More importantly, this regulation signals a shift in how regulators assess packaging safety. PFAS are persistent — they do not break down in the environment or the human body. The FSA and UK Environmental Agency are watching this regulation closely, and UK-specific restrictions may follow.
From a food safety perspective, this is not a HACCP issue (PFAS is not a microbiological, chemical, or physical hazard in the traditional sense) — it is a prerequisite programme and supply chain assurance issue. Under BRC Issue 9 clause 2.1 (PRP selection and implementation), packaging sourcing and supplier verification form part of your documented prerequisite system. If your current supplier approval process does not verify PFAS compliance, you have a gap.
What You Need to Do Before August 12, 2026
First, audit your current packaging suppliers. Send a questionnaire to every packaging vendor: "Does your product comply with EU PPWR PFAS limits of 25 ppb (single compound) and 250 ppb (sum of targeted PFAS)?" Request evidence — a certificate of compliance, a supplier declaration, or third-party testing data. Many suppliers have already transitioned to PFAS-free formulations; some have not. If a supplier cannot provide evidence by July 2026, you must identify an alternative source now.
Second, review your packaging stock. If you hold EU-sourced packaging manufactured before August 2026 but intend to use it after the deadline, that use will technically violate the regulation in the EU. For UK-only distribution, there is less immediate legal risk, but reputational and customer pressure will increase. Many retailers and brand owners are already requiring PFAS-free packaging certificates from all suppliers.
Third, update your supplier approval documentation. Under BRC Issue 9 clause 2.5 (supplier approval and monitoring), your food safety manual should specify that all packaging suppliers must provide evidence of PFAS compliance. Document the verification step — which supplier provided what documentation and when. This audit trail is what an auditor or EHO expects to see.
Fourth, communicate with your customers. If you are a food manufacturer using imported packaging, your retail customer may have already requested confirmation that you will meet the August 12 deadline. Respond proactively with a letter stating your packaging compliance status.
How This Relates to Your HACCP System
PFAS in packaging is not a CCP (Critical Control Point) or an OPRP (Operational Prerequisite Programme control) in the traditional sense, because PFAS does not pose an immediate acute food safety hazard. However, migration of PFAS from packaging into food is a chemical hazard. Under Codex Alimentarius CXC 1-1969 Step 4 (identify the hazards), packaging composition is an identified hazard in food manufacturing. Your hazard analysis should acknowledge that packaging-sourced PFAS is a potential concern.
Your control for this hazard is supplier verification and packaging approval — a PRP under BRC 2.1 and 2.5. You cannot inspect PFAS in packaging; you rely on supplier documentation and testing data. This is exactly how prerequisite programmes work: you establish a supplier assurance control outside of the HACCP plan but within your food safety management system.
Strengthen Your Control with SafetyCore
SafetyCore's supplier management module allows you to document packaging supplier approval, track compliance certifications, and set review dates. If a supplier certification expires or a new regulation comes into effect (like the August 12 deadline), you can flag the requirement and assign verification tasks to the responsible team member. The audit trail shows exactly when you requested PFAS compliance evidence and which supplier provided it.
SafetyCore's prerequisite programme management links your packaging sourcing control directly to your HACCP plan. When you review your hazard analysis (Step 4), you can reference your supplier approval records. If a supplier fails to provide PFAS compliance evidence, SafetyCore prompts a corrective action: identify an alternative source, update your supplier risk assessment, and document the decision. This creates the paper trail that regulators and auditors want to see.
Conclusion
The August 12, 2026 PFAS deadline is not just a regulatory box to tick — it is a reminder that food safety control extends beyond your factory walls into your supply chain. A Technical Manager who waits until July 2026 to ask suppliers about PFAS compliance will find that alternatives have limited stock or longer lead times. The time to act is now: audit your suppliers, verify compliance, update your food safety documentation, and ensure every team member involved in packaging sourcing knows the deadline and the requirement.
If you are reviewing your packaging supplier controls and HACCP prerequisite programmes, SafetyCore gives you a structured way to verify compliance and maintain the audit trail. Start a free trial at safetycore.co.uk.